[May 14, 2013 VIA EDGAR Office of Beverages, Apparel, and Mining 100 F Street, N.E. Re: China New Borun Corporation (the “Company”) Form 20-F for the Fiscal Year Ended December 31, 2011 Filed April 6, 2012 File No. 001-34754 Dear Ms. Jenkins: * * * Item 5. Operating Financial Review and Prospectus, page 66 1. We partially reissue comment 2]
[April 28, 2013 Ms. Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining Division of Corporation Finance 100 F Street NE Re: China New Borun Corporation Form 20-F for Fiscal Year Ended December 31, 2011 Filed April 6, 2012 Correspondence submitted March 25, 2013 File No. 001-34754 Dear Ms. Jenkins: I refer to your letter dated]
[April 28, 2013 Ms. Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining Division of Corporation Finance 100 F Street NE Re: China New Borun Corporation Form 20-F for Fiscal Year Ended December 31, 2011 Filed April 6, 2012 Correspondence submitted March 25, 2013 File No. 001-34754 Dear Ms. Jenkins: I refer to your letter dated]
[None (Title of Class) Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report. 25,725,000 Ordinary Shares, par value $0.001 per share, as of December 31, 2012 o x Yes o x Yes x o Yes o o Yes o Large] [No: 23060500-2012 Nian Qing Ying Di Zi No. 0017 THE MORTGAGE CONTRACT AGRICULTURAL DEVELOPMENT BANK OF CHINA Mortgagor (in full): Daqing Borun Biotechnology Co., Ltd Business License Number: 230606100202956 Legal Representative (Main Responsible Officer): Wang Jinmiao Address: Jubao Village, Zhusan Township, Datong District, Daqing Postal code: 163515 Bank of Basic Deposit Account and Account Number: Daqing Datong Branch of Longjiang] [Mortgage (Counter Security) Contract 20120911 No.: China Prosperous Cooperated & Solidarized (Security) Counter Mortgage (Corn) No. The Mortgagee: China Prosperous Cooperated & Solidarized Financing Guarantee Co., Ltd (Hereinafter referred to as “Party A”) Responsible Person: WANG Jiangong Correspondence Address: No. 12 Chuiliu Road, Tongzhou Industrial Development Zone, Tongzhou District, Beijing Tel: 010-83224816 Fax: 010-83224889 Postal Code: 100000 The Mortgagor: Daqing] [Guaranty Contract (Counter Security) Debtor: Daqing Borun Biotechnology Co., Ltd Counter-Guarantor (Party A): Shandong Borun Industrial Co., Ltd Guarantor (Party B): Heilongjiang Zeyu Financing and Security Co., Ltd Guaranty Contract (Counter Security) Party A: (full name) Shandong Borun Industrial Co., Ltd Legal Representative: WANG Jinmiao Address (Correspondence Address): South, Bohai Industrial Park, Shouguang City (south of Yangkou Town) Tel and] [No.: Zhong Lv Bao Di Zi 2012 24 [0 Counter-Guarantee (Mortgage) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Counter-Guarantee (Mortgage/Pledge) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Daqing Borun Biotechnology Co., Ltd. the Debtor Daqing Branch of Agricultural] [No.: Zhong Lv Bao Di Zi 2012 24 [0 Counter-Guarantee (Mortgage) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Counter-Guarantee (Mortgage/Pledge) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Daqing Borun Biotechnology Co., Ltd. the Debtor Daqing Branch of Agricultural] [Year 2012 Dongjianzi No. 014 Agreement No.: Commodity Financing Pledge Supervision Agreement (For rolling pledge) INDUSTRIAL AND COMMERCIAL BANK OF CHINA CO., LTD. CHINA NATIONAL FOREIGN TRADE TRANSPORTATION (GROUP) CORPORATION Party A (pledgee): Industrial and Commercial Bank of China Co., Ltd. Daqing Branch Address: No. 37, Dongfeng Road Saertu District, Daqing Party B (pledgor): Daqing Borun Biotechnology Co., Ltd. Domicile] [] [CERTIFICATIONS I, Jinmiao Wang, certify that: 1. I have reviewed this annual report on Form 20-F of China New Borun Corporation (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which] [CERTIFICATIONS I, Yuanqin (Terence) Chen, certify that: 1. I have reviewed this annual report on Form 20-F of China New Borun Corporation (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under] [CERTIFICATIONS (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Jinmiao Wang Chairman and Chief Executive Officer] [CERTIFICATIONS (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Yuanqin (Terence) Chen Chief Financial Officer] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM China New Borun Corporation Bohai Industrial Park, Yangkou Town Shouguang, Shandong 262715 People’s Republic of China We hereby consent to the incorporation by reference in the Registration Statement on Form F-1 (File No. 333-166312) of China New Borun Corporation and its subsidiaries (the “Company”) of our report dated April 24, 2013, relating to]
[None (Title of Class) Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report. 25,725,000 Ordinary Shares, par value $0.001 per share, as of December 31, 2012 o x Yes o x Yes x o Yes o o Yes o Large] [No: 23060500-2012 Nian Qing Ying Di Zi No. 0017 THE MORTGAGE CONTRACT AGRICULTURAL DEVELOPMENT BANK OF CHINA Mortgagor (in full): Daqing Borun Biotechnology Co., Ltd Business License Number: 230606100202956 Legal Representative (Main Responsible Officer): Wang Jinmiao Address: Jubao Village, Zhusan Township, Datong District, Daqing Postal code: 163515 Bank of Basic Deposit Account and Account Number: Daqing Datong Branch of Longjiang] [Mortgage (Counter Security) Contract 20120911 No.: China Prosperous Cooperated & Solidarized (Security) Counter Mortgage (Corn) No. The Mortgagee: China Prosperous Cooperated & Solidarized Financing Guarantee Co., Ltd (Hereinafter referred to as “Party A”) Responsible Person: WANG Jiangong Correspondence Address: No. 12 Chuiliu Road, Tongzhou Industrial Development Zone, Tongzhou District, Beijing Tel: 010-83224816 Fax: 010-83224889 Postal Code: 100000 The Mortgagor: Daqing] [Guaranty Contract (Counter Security) Debtor: Daqing Borun Biotechnology Co., Ltd Counter-Guarantor (Party A): Shandong Borun Industrial Co., Ltd Guarantor (Party B): Heilongjiang Zeyu Financing and Security Co., Ltd Guaranty Contract (Counter Security) Party A: (full name) Shandong Borun Industrial Co., Ltd Legal Representative: WANG Jinmiao Address (Correspondence Address): South, Bohai Industrial Park, Shouguang City (south of Yangkou Town) Tel and] [No.: Zhong Lv Bao Di Zi 2012 24 [0 Counter-Guarantee (Mortgage) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Counter-Guarantee (Mortgage/Pledge) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Daqing Borun Biotechnology Co., Ltd. the Debtor Daqing Branch of Agricultural] [No.: Zhong Lv Bao Di Zi 2012 24 [0 Counter-Guarantee (Mortgage) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Counter-Guarantee (Mortgage/Pledge) Agreement Mortgagor (Party A): Daqing Borun Biotechnology Co., Ltd. Mortgagee (Party B): Zhong Lv Credit Guarantee Co., Ltd. Daqing Borun Biotechnology Co., Ltd. the Debtor Daqing Branch of Agricultural] [Year 2012 Dongjianzi No. 014 Agreement No.: Commodity Financing Pledge Supervision Agreement (For rolling pledge) INDUSTRIAL AND COMMERCIAL BANK OF CHINA CO., LTD. CHINA NATIONAL FOREIGN TRADE TRANSPORTATION (GROUP) CORPORATION Party A (pledgee): Industrial and Commercial Bank of China Co., Ltd. Daqing Branch Address: No. 37, Dongfeng Road Saertu District, Daqing Party B (pledgor): Daqing Borun Biotechnology Co., Ltd. Domicile] [] [CERTIFICATIONS I, Jinmiao Wang, certify that: 1. I have reviewed this annual report on Form 20-F of China New Borun Corporation (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which] [CERTIFICATIONS I, Yuanqin (Terence) Chen, certify that: 1. I have reviewed this annual report on Form 20-F of China New Borun Corporation (the “Company”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under] [CERTIFICATIONS (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Jinmiao Wang Chairman and Chief Executive Officer] [CERTIFICATIONS (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Yuanqin (Terence) Chen Chief Financial Officer] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM China New Borun Corporation Bohai Industrial Park, Yangkou Town Shouguang, Shandong 262715 People’s Republic of China We hereby consent to the incorporation by reference in the Registration Statement on Form F-1 (File No. 333-166312) of China New Borun Corporation and its subsidiaries (the “Company”) of our report dated April 24, 2013, relating to]
[March 25, 2013 VIA EDGAR Office of Beverages, Apparel, and Mining 100 F Street, N.E. Re: China New Borun Corporation (the “Company”) Form 20-F for the Fiscal Year Ended December 31, 2011 Filed April 6, 2012 File No. 001-34754 Dear Ms. Jenkins: * * * Item 3. Key Information, page 7 D. Risk Factors, page 9 1. As a public]
[March 25, 2013 VIA EDGAR Office of Beverages, Apparel, and Mining 100 F Street, N.E. Re: China New Borun Corporation (the “Company”) Form 20-F for the Fiscal Year Ended December 31, 2011 Filed April 6, 2012 File No. 001-34754 Dear Ms. Jenkins: * * * Item 3. Key Information, page 7 D. Risk Factors, page 9 1. As a public]
[March 14, 2013 Ms. Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining Division of Corporation Finance Re: China New Borun Corporation Form 20-F for Fiscal Year Ended December 31, 2011 Filed April 6, 2012 Correspondence submitted January 31, 2013 File No. 001-34754 Dear Ms. Jenkins: I refer to your letter dated March 5, 2013, relating]
